GE India Technology Centre Pvt. Ltd. v. CIT

327 ITR 456Supreme Court of India2010#85 most cited

What is GE India Technology Centre Pvt. Ltd. v. CIT authority for?

Tax must be deducted at source from payments made to a non-resident under Section 195 only if such payment is chargeable to tax in India. The Assessing Officer bears the onus to establish that the payments made are indeed chargeable to tax under the Income Tax Act.

663

judgments rely on this decision, according to BharatTax’s citation analysis of 372,250 Indian tax judgments — from 2013 to 2026.

Also referred to as

GE India Technology Centre Pvt. Ltd. v. CIT · Section 195 · Section 40(a)(i) · TDS non-resident · withholding tax India · payment chargeable to tax · liability to deduct tax · income tax non-resident · tax deduction at source

Sections most often in play

Section 195Section 40(a)(i)Section 40(a)(ia)Section 143(3)Section 115JBSection 201(1A)Section 14ASection 201(1)
Read the full judgment

Issues it is cited on

section 5(2)(b)section 9(1)(vii)(b)section 195(1)section 9(1)(i)section 195(2)section 5(2)section 40(a)(i)section 195fees for included servicessection 9(1)(vii)business connectionsection 9(1)

Judgments citing GE India Technology Centre Pvt. Ltd. v. CIT

DCIT 7(3), Mumbai vs. United Home Entertainment P.Ltd, Mumbai

In the result, the appeal of the assessee for the assessment year 2009-10 is partly allowed for statistical purposes

ITA 3385/MUM/2013[2008-09]Status: DisposedITAT Mumbai31 Mar 2016AY 2008-09
Section 143(3)Section 40A(2)Section 40A(2)(b)

…e as well. There is no estoppel against the statute. As for the question of approaching the tax authorities under section 195(2), the law is now well settled by Hon’ble Supreme Court in the case of GE India Information Technology Centre Pvt Ltd Vs CIT [(2010) 327 ITR 456 (SC)] which holds that unless the recipient of income has a tax liability in respect of such payments, the person making the payment cannot be saddled with the tax deduction liability just because he did not approach the tax authorities under section 195(2). The grievances raised by the Assessing Officer are thus devoid of any legally sustainable…

ITO (TDS), New Delhi vs. Bharti Airtel Ltd., Gurgaon

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 4077/DEL/2012[2009-10 (F.Y. 2008-09)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…ing a payment to a person who is a non-resident, of any sum, which is chargeable to Tax under the Act, is required to deduct the tax thereon at the rates in force. The Hon’ble Supreme Court of India in the case of GE Technology Central (P) Ltd. vs. CIT (2010) 327 ITR 456 (SC) held that the payer becomes an ITA Nos. 3593 TO 3596/Del/2012 [Bharti Airtel Ltd. vs. ITO(TDS)] & ITA Nos. 4076 TO 4079/Del/2012 [ITO(TDS) vs. Bharti Airtel Ltd.] assessee in default, only when he fails in his statutory obligations under section 195(1) of the Act. If the payment does not contain an element of income, the payer cannot be made…

ITO (TDS), New Delhi vs. Bharti Airtel Ltd., Gurgaon

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 4076/DEL/2012[2008-09 (F.Y. 2007-08)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…ing a payment to a person who is a non-resident, of any sum, which is chargeable to Tax under the Act, is required to deduct the tax thereon at the rates in force. The Hon’ble Supreme Court of India in the case of GE Technology Central (P) Ltd. vs. CIT (2010) 327 ITR 456 (SC) held that the payer becomes an ITA Nos. 3593 TO 3596/Del/2012 [Bharti Airtel Ltd. vs. ITO(TDS)] & ITA Nos. 4076 TO 4079/Del/2012 [ITO(TDS) vs. Bharti Airtel Ltd.] assessee in default, only when he fails in his statutory obligations under section 195(1) of the Act. If the payment does not contain an element of income, the payer cannot be made…

Bharti Airtel Ltd., Gurgaon vs. ITO (TDS), New Delhi

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 3596/DEL/2012[2011-12 (F.Y. 2010-11)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…ing a payment to a person who is a non-resident, of any sum, which is chargeable to Tax under the Act, is required to deduct the tax thereon at the rates in force. The Hon’ble Supreme Court of India in the case of GE Technology Central (P) Ltd. vs. CIT (2010) 327 ITR 456 (SC) held that the payer becomes an ITA Nos. 3593 TO 3596/Del/2012 [Bharti Airtel Ltd. vs. ITO(TDS)] & ITA Nos. 4076 TO 4079/Del/2012 [ITO(TDS) vs. Bharti Airtel Ltd.] assessee in default, only when he fails in his statutory obligations under section 195(1) of the Act. If the payment does not contain an element of income, the payer cannot be made…

Bharti Airtel Ltd., Gurgaon vs. ITO (TDS), New Delhi

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 3595/DEL/2012[2010-11 (F.Y. 2009-10)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…ing a payment to a person who is a non-resident, of any sum, which is chargeable to Tax under the Act, is required to deduct the tax thereon at the rates in force. The Hon’ble Supreme Court of India in the case of GE Technology Central (P) Ltd. vs. CIT (2010) 327 ITR 456 (SC) held that the payer becomes an ITA Nos. 3593 TO 3596/Del/2012 [Bharti Airtel Ltd. vs. ITO(TDS)] & ITA Nos. 4076 TO 4079/Del/2012 [ITO(TDS) vs. Bharti Airtel Ltd.] assessee in default, only when he fails in his statutory obligations under section 195(1) of the Act. If the payment does not contain an element of income, the payer cannot be made…

Bharti Airtel Ltd., Gurgaon vs. ITO (TDS), New Delhi

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 3594/DEL/2012[2009-10 (F.Y. 2008-09)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…ing a payment to a person who is a non-resident, of any sum, which is chargeable to Tax under the Act, is required to deduct the tax thereon at the rates in force. The Hon’ble Supreme Court of India in the case of GE Technology Central (P) Ltd. vs. CIT (2010) 327 ITR 456 (SC) held that the payer becomes an ITA Nos. 3593 TO 3596/Del/2012 [Bharti Airtel Ltd. vs. ITO(TDS)] & ITA Nos. 4076 TO 4079/Del/2012 [ITO(TDS) vs. Bharti Airtel Ltd.] assessee in default, only when he fails in his statutory obligations under section 195(1) of the Act. If the payment does not contain an element of income, the payer cannot be made…

Bharti Airtel Ltd., Gurgaon vs. ITO (TDS), New Delhi

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 3593/DEL/2012[2008-09 (F.Y. 2007-08)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…ing a payment to a person who is a non-resident, of any sum, which is chargeable to Tax under the Act, is required to deduct the tax thereon at the rates in force. The Hon’ble Supreme Court of India in the case of GE Technology Central (P) Ltd. vs. CIT (2010) 327 ITR 456 (SC) held that the payer becomes an ITA Nos. 3593 TO 3596/Del/2012 [Bharti Airtel Ltd. vs. ITO(TDS)] & ITA Nos. 4076 TO 4079/Del/2012 [ITO(TDS) vs. Bharti Airtel Ltd.] assessee in default, only when he fails in his statutory obligations under section 195(1) of the Act. If the payment does not contain an element of income, the payer cannot be made…

Boscj Limited, Bangalore vs. DCIT, Bangalore

In the result, the appeal filed by the assessee company is treated as

ITA 1583/BANG/2014[2012-13]Status: DisposedITAT Bangalore01 Mar 2016AY 2012-13

Bench: Smt Asha Vijayaraghavan & Shri Inturi Rama Rao

For Appellant: Shri K.P.Kumar, Sr. CounselFor Respondent: Smt. Rukmani Attri, JCIT
Section 195Section 201(1)Section 40Section 95

…ability to deduct tax at source arises only when there is accrual of income in the hands of the payee. We are holding so, keeping in view the ratio laid down by the Hon’ble Apex Court in the case of M/s GE India Technology Centre P. Ltd. Vs. CIT and another 327 ITR 456 (SC) wherein the Hon’ble Supreme Court held that if payment is not assessable to tax there is no question of tax at source being deducted. The relevant portion of the judgment is reproduced as under :- “If the contention of the Department that the moment there is remittance the obligation to deduct TAS arises is to ITA No.1583(B)/2014 be acce…

Central Electronics Ltd., Uttar Pradesh vs. DCIT, New Delhi

In the result, the appeal of the assessee is allowed

ITA 207/DEL/2014[2010-11]Status: DisposedITAT Delhi24 Feb 2016AY 2010-11

Bench: Smt. Diva Singh & Sh. O.P. Kantassessment Year: 2010-11 Ddit, Circle-3(1), 3Rd Floor, C.R. Central Electronics Ltd., 4, Vs. Industrial Area, Sahibabad, Uttar Building, I.P. Estate, New Delhi Pradesh. (Pan:Aaacc1262G) (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 195Section 40Section 42Section 43BSection 9(1)(vii)

…Court, held as under: “…………………………………. In the light of the judgments of the Supreme Court in Commissioner of Income Tax Vs. Eli Lilly and Co. (India) P. Ltd. [2009], 312 ITR 225 (SC) and GE India Technology Centre P. Ltd. Vs. Commissioner of Income Tax [2010] 327 ITR 456 (SC), once the income was not exigible or chargeable to tax, TDS was not required to be deducted. Money paid to the third parties, who did not have any office or permanent establishment in India, was exempt and not chargeable to tax. Thus, on the said payments or income, TDS was not required to be deducted. We also note that the payments in quest…

M/S Wipro Ltd vs. ITO

In the result, the appeals of the assessee are allowed and S

ITA 1544/BANG/2013[2010-11]Status: DisposedITAT Bangalore12 Feb 2016AY 2010-11

Bench: Shri Abraham P George & Shri Vijaypal Rao

For Appellant: Shri B.K. Manjunatha, C.AFor Respondent: Shri Rajashekar, Addl. CIT (D.R)
Section 139ASection 156Section 200ASection 206ASection 90(2)Section 90A(2)

…TR 225 (SC) observed that the provisions of tax withholding i.e. section 195 of the Act would apply only to sums which are otherwise chargeable to tax under the Act. The Hon’ble Supreme Court in the case of GE India Technology Centre Pvt. Ltd. vs. CIT, (2010) 327 ITR 456 (SC) held that the provisions of DTAAs along with the sections 4, 5, 9, 90 & 91 of the Act are relevant while applying the provisions of tax deduction at source. Therefore, in view of the aforesaid schematic interpretation of the Act, section 206AA of the Act cannot be understood to override the charging sections 4 and 5 of the Act. Thus, where s…

Pahilajrai Jaikishan, Mumbai vs. DCIT 19(3), Mumbai

In the result, the appeal is allowed

ITA 994/MUM/2014[2010-11]Status: DisposedITAT Mumbai01 Feb 2016AY 2010-11

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

Section 14Section 143(2)Section 143(3)Section 14ASection 37(1)Section 40

…es not apply when no income is found to be taxable in India, therefore, there was no reason for making any disallowance under provisions of Section 40(a)(i) in view of decision of the Hon’ble Supreme Court in the case of G.E.India Technology Centre Pvt. Ltd., 327 ITR 456. There are also judicial pronouncements supporting this proposition, which are reported in 10 ITR 501(Trib), 86 ITD 102 and 10 ITR 147(Trib). 10. Payment of brokerage to the said non-resident brokers for non technical services is the business income of the payee and therefore, not liable to tax in India as was held in the case of Sri Subharaman…

Asst CIT 19(3), Mumbai vs. Pahilajrai Jaikishin, Mumbai

In the result, the appeal is allowed

ITA 1562/MUM/2014[2010-11]Status: DisposedITAT Mumbai01 Feb 2016AY 2010-11

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

Section 14Section 143(2)Section 143(3)Section 14ASection 37(1)Section 40

…es not apply when no income is found to be taxable in India, therefore, there was no reason for making any disallowance under provisions of Section 40(a)(i) in view of decision of the Hon’ble Supreme Court in the case of G.E.India Technology Centre Pvt. Ltd., 327 ITR 456. There are also judicial pronouncements supporting this proposition, which are reported in 10 ITR 501(Trib), 86 ITD 102 and 10 ITR 147(Trib). 10. Payment of brokerage to the said non-resident brokers for non technical services is the business income of the payee and therefore, not liable to tax in India as was held in the case of Sri Subharaman…

Khemchand Sons, Mumbai vs. Addl. C.I.T.-14(2), Mumbai

In the result, appeal filed by the assessee is partly allowed

ITA 1611/MUM/2011[2007-08]Status: DisposedITAT Mumbai06 Jan 2016AY 2007-08

Bench: Shri Sanjay Garg & Shri Ashwani Tanejaassessment Year: 2009-10 Khemchand Sons, Addl. Cit-14(2) 407, Gazdar House, 629A, बनाम/ Earnest House, Kalbadevi Rd. Nariman Point, Vs. Mumbai -400002 Mumbai-400020 (Assessee) (Revenue) P.A. No.Aaafk0375J "नधा"रती क" ओर से / Assessee By Shri Nitesh Joshi (Ar) Shri B. Yadagiri (Dr) राज"व क" ओर से / Revenue By 7/12/2015 सुनवाई क" तार"ख / Date Of Hearing : 06/1/2016 आदेश क" तार"ख /Date Of Order:

Section 143(3)(ii)Section 195Section 40

…आयकर अपील"य अ"धकरण, मुंबई "यायपीठ,I,मुंबई । IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “I”, MUMBAI "ी संजय गग", "या"यक सद"य एवं "ी अ"वनी तनेजा, लेखा सद"य, के सम" Before Shri Sanjay Garg, Judicial Member, and Shri Ashwani Taneja, Accountant Member Assessment Year: 2009-10 Khemchand Sons, Addl. CIT-14(2) 407, Gazdar House, 629A, बनाम/ Earnest House, Kalbadevi Rd. Nariman Point, Vs. Mumbai -400002 Mumbai-400020 (Assessee) (Revenue) P.A. No.AAAFK0375J "नधा"रती क" ओर से / Assessee by Shri Nitesh Joshi (AR) Shri B. Yadagiri (DR) राज"व क" ओर से / Revenue by 7/12/2015 सुनवाई क" तार"ख / Date of Hearing : 06/1/2…

DCIT vs. Treads Direct Limited, Coimbatore

In the result, the appeal of the assessee is partly allowed for statistical purposes and the appeal of the Revenue is dismissed

ITA 2941/CHNY/2014[2010-11]Status: DisposedITAT Chennai30 Dec 2015AY 2010-11

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri. Philip George, Advocate
Section 143(1)Section 143(2)Section 143(3)Section 36Section 36(1)

…of the Act income should be chargeable to tax in India, which is clearly not so in the instant case. In view of the above discussion and respectfully following the judgement of the Hon'ble Supreme Court in the case of GE India Technology Centre P. Ltd. v CIT 327 ITR 456, he directed the Assessing Officer to delete the addition made towards foreign agency commission, warehousing and other charges u/s 40(a)(i) of the Act. According, the Commissioner of Income Tax (Appeals) allowed this ground. Against this, the assessee is in appeal before us. 13. We have heard both the sides and perused the material on record. I…

Treadsdirect Limited, Coimbatore vs. JCIT, Coimbatore

In the result, the appeal of the assessee is partly allowed for statistical purposes and the appeal of the Revenue is dismissed

ITA 2794/CHNY/2014[2010-2011]Status: DisposedITAT Chennai30 Dec 2015AY 2010-2011

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri. Philip George, Advocate
Section 143(1)Section 143(2)Section 143(3)Section 36Section 36(1)

…of the Act income should be chargeable to tax in India, which is clearly not so in the instant case. In view of the above discussion and respectfully following the judgement of the Hon'ble Supreme Court in the case of GE India Technology Centre P. Ltd. v CIT 327 ITR 456, he directed the Assessing Officer to delete the addition made towards foreign agency commission, warehousing and other charges u/s 40(a)(i) of the Act. According, the Commissioner of Income Tax (Appeals) allowed this ground. Against this, the assessee is in appeal before us. 13. We have heard both the sides and perused the material on record. I…

DCIT, Bangalore vs. M/S Sjs Enterprises Pvt. Ltd., Bangalore

In the result, the Revenue’s appeal is dismissed

ITA 680/BANG/2014[2009-10]Status: DisposedITAT Bangalore28 Dec 2015AY 2009-10

Bench: Smt. Asha Vijayaraghavan & Shri Abraham P. Georgeassessment Year : 2009-10

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Sunil Kumar Agarwala, Jt. CIT(DR)

…‘D’ Bench in the case of DCIT Range-7(2), Mumbai Vs. Rediff.com India Ltd., in Appeal No.3061 (Mum.) of 2009 held that ‘As held by the Supreme Court ITA No.680 & 660/Bang/2014 Page 16 of 26 in the case of GE India Technology Centre Pvt. Ltd., Vs. CIT (2010) 327 ITR 456/193 Taxman 234, tax deduction at source obligations u/s 195(1) arise only if the payment is chargeable to tax in the hands of non-resident recipient. Therefore, merely because a person has not deducted tax at source from a remittance abroad, it cannot be inferred that the person making the remittance has committed a default in discharging his tax…

Sjs Enterprises Pvt. Ltd., Bangalore vs. DCIT, Bangalore

In the result, the Revenue’s appeal is dismissed

ITA 660/BANG/2014[2009-10]Status: DisposedITAT Bangalore28 Dec 2015AY 2009-10

Bench: Smt. Asha Vijayaraghavan & Shri Abraham P. Georgeassessment Year : 2009-10

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Sunil Kumar Agarwala, Jt. CIT(DR)

…‘D’ Bench in the case of DCIT Range-7(2), Mumbai Vs. Rediff.com India Ltd., in Appeal No.3061 (Mum.) of 2009 held that ‘As held by the Supreme Court ITA No.680 & 660/Bang/2014 Page 16 of 26 in the case of GE India Technology Centre Pvt. Ltd., Vs. CIT (2010) 327 ITR 456/193 Taxman 234, tax deduction at source obligations u/s 195(1) arise only if the payment is chargeable to tax in the hands of non-resident recipient. Therefore, merely because a person has not deducted tax at source from a remittance abroad, it cannot be inferred that the person making the remittance has committed a default in discharging his tax…

DCIT, Circle - 8, Kolkata vs. M/S. E.I.H. Ltd., Kolkata

In the result, the appeal of the revenue in ITA NO

ITA 2182/KOL/2006[2003-04]Status: DisposedITAT Kolkata09 Dec 2015AY 2003-04

Bench: : Shri M. Balaganesh

For Appellant: Shri R.N Bajoria, Sr.Advocate &For Respondent: Shri Rajat Subhra Biswas, ld.CIT/DR
Section 143(3)Section 195Section 40Section 9(1)(vii)

…the part of the assessee to deduct tax at source in terms of section 195 of the Act. This issue is squarely covered in favour of the assessee by the decision of the Hon’ble Apex Court in the case of GE India Technology Centre (P) Ltd vs CIT reported in (2010) 327 ITR 456 (SC). Hence no disallowance could be made u/s 40(a)(i) of the Act for the same. ITA Nos. 2182/Kol/06, 57, 1876 & 1846/Kol/07, 196 & 4 299/Kol/2010 DCIT,Cir-8, Kol Vs. M/s. E I H Ltd We also find that the said services are governed by Article 14 of DTAA as per which the said payments are not liable to be taxed in India. It is well settled that…

Cebon Apparel Pvt. Ltd., Mumbai vs. Addl CIT 6(2), Mumbai

ITA 2122/MUM/2011[2005-06]Status: DisposedITAT Mumbai30 Nov 2015AY 2005-06

Bench: Shri R.C. Sharma & Shri Sanjay Garg

For Appellant: Shri J.D. Mistry, A.R. & Shri K.K. Ved, A.RFor Respondent: Shri Vivek A. Perumpurna, D.R
Section 143(2)Section 147Section 148Section 195

…25,661/- under section 40(a)(i) of the Act. The Ld. CIT(A) confirmed the disallowance so made by the AO. The assessee has, thus, come in appeal before us. 8. It may be observed that the Hon’ble Supreme Court in the case of GEI Technology Centre vs CIT (2010) 327 ITR 456 has held that the obligation u/s 195(1) arises only if the payment is chargeable to tax in India in the hands of non-resident recipient. The Ld. A.R. of the assessee has submitted that the assessee had given full details of the expenses incurred outside India. He has submitted that the lower authorities have not given a categorical finding as to…

Cebon Apparel Pvt. Ltd., Mumbai vs. ACIT Cir 6(2), Mumbai

ITA 2120/MUM/2011[2003-04]Status: DisposedITAT Mumbai30 Nov 2015AY 2003-04

Bench: Shri R.C. Sharma & Shri Sanjay Garg

For Appellant: Shri J.D. Mistry, A.R. & Shri K.K. Ved, A.RFor Respondent: Shri Vivek A. Perumpurna, D.R
Section 143(2)Section 147Section 148Section 195

…25,661/- under section 40(a)(i) of the Act. The Ld. CIT(A) confirmed the disallowance so made by the AO. The assessee has, thus, come in appeal before us. 8. It may be observed that the Hon’ble Supreme Court in the case of GEI Technology Centre vs CIT (2010) 327 ITR 456 has held that the obligation u/s 195(1) arises only if the payment is chargeable to tax in India in the hands of non-resident recipient. The Ld. A.R. of the assessee has submitted that the assessee had given full details of the expenses incurred outside India. He has submitted that the lower authorities have not given a categorical finding as to…

GE India Technology Centre Pvt. Ltd. v. CIT (327 ITR 456) — Cited in 663 Judgments | BharatTax